Natural Flavoring


My husband recently attended a peanut allergy support group meeting. Several members recommended that foods labelled with "natural flavoring" as an ingredient should be avoided because they may contain peanuts. I have not seen this ingredient discussed here or at the Food Allergy Network's website. Can anyone substantiate this information?

On Feb 26, 1999

Beverly, natural flavoring is a difficult one to get a straight answer on. I have called the Food Allergy Network in the past, and they have recommended to check the natural flavoring. I have copied a site from the FDA - They highly recommend manufacturers to note the allergen even if it is included in natural flavoring. I try to stay with the large companies, Kraft, General Mills, etc. They work closely with FAN and seem to take a recommendation from the FDA as a requirement. The FDA information does seem to encourage, if not request labeling of allergens in natural flavorings. I did call the local FDA office and one from another state and seemed to get different feedback on the requirement. The FDA information copied from the FDA site is as follows: U. S. Food and Drug Administration Center for Food Safety and Applied Nutrition June 10, 1996


Label Declaration of Allergenic Substances in Foods

This letter is to make you aware of the Food and Drug Administration's (FDA's) concerns regarding the labeling of foods that contain allergenic substances. Recently, FDA has received a number of reports concerning consumers who experienced adverse reactions following exposure to an allergenic substance in foods. These exposures occurred because the presence of the allergenic substance in the food was not declared on the food label.

The Food, Drug, and Cosmetic Act (the act) requires, in virtually all cases, a complete listing of all the ingredients of a food. Two of the very narrow exemptions from ingredient labeling requirements appear to have been involved in a number of the recent incidents, however. First, section 403(i) of the act provides that spices, flavorings, and colorings may be declared collectively without naming each one. Secondly, FDA regulations (21 CFR 101.100(a)(3)) exempt from ingredient declaration incidental additives, such as processing aids, that are present in a food at insignificant levels and that do not have a technical or functional effect in the finished food.

In some of the instances of adverse reactions, failure to declare an ingredient appears to have been the result of a misinterpretation of the exemption from ingredient declaration provided for incidental additives in 101.100(a)(3). FDA reminds manufacturers that to qualify for the exemption from ingredient declaration provided for incidental additives and processing aids, a substance must meet both of the requirements of 101.100(a)(3), i.e., it must be present in the food at an insignificant level, and it must not have any technical or functional effect in the finished food. Thus, incidental additives may include substances that are present in a food by virtue of their incorporation as an ingredient in another food. However, when an ingredient added to another food continues to have an effect in the finished food (e.g., egg white as a binder in breading used on a breaded fish product), the ingredient is not an incidental additive, and its use must be declared on the label.

The recent adverse reaction reports indicate that some manufacturers have also incorrectly interpreted what constitutes an insignificant level of a substance. Clearly, an amount of a substance that may cause an adverse reaction is not insignificant. Because evidence suggests that some allergenic substances can cause serious allergic responses in some individuals upon ingestion of very small amounts of the substance, it is unlikely that such an allergen, when it is present in a food, can be present at an insignificant level. Thus, it follows that the requirements of 101.100(a)(3) can not be met under such circumstances.

FDA is considering whether it is necessary to clarify its regulations to ensure that manufacturers fully understand the circumstances in which allergenic food ingredients must be declared and to ensure that sensitive individuals are protected by appropriate labeling.

We have also received reports of adverse reactions to foods in which likely allergenic substances were used as flavors, and not declared by name. Therefore, in addition to the exemption in 101.100(a)(3), the agency is also considering whether an allergenic ingredient in a spice, flavor, or color should be required to be declared, 403(i) not withstanding. On a substance-by-substance basis, the agency has required ingredients covered by the exemption in section 403(i) to be declared when necessary to protect individuals who experience adverse reactions to the substance, e.g., FD&C Yellow No. 5. The agency is open to suggestions on how to best address this problem.

While FDA has not formally defined "allergens," it provided examples of foods that are among the most commonly known to cause serious allergenic responses, i.e., milk, eggs, fish, crustacea, mollusks, tree nuts, wheat, and legumes (particularly peanuts and soybeans), in a policy statement dealing with foods derived from new plant varieties published in the FEDERAL REGISTER of May 29, 1992 (57 FR 22984 at 22987).

FDA advises that the issue of declaring allergenic ingredients in food is being discussed on an international level. Several individual governments and the Codex Alimentarius Commission have begun to formulate policy for the labeling of foods containing allergenic ingredients to ensure that consumers are provided sufficient information to avoid substances to which they are allergic. While packaged foods sold in the U.S. are among the most comprehensively labeled foods in the world (some countries provide broader exemptions from ingredient declaration), FDA is studying its labeling requirements, and considering whether rulemaking is necessary, for the labeling of allergenic ingredients.

While the agency does so, FDA asks manufacturers to examine their product formulations for ingredients and processing aids that contain known allergens that they may have considered to be exempt from declaration as incidental additives under 101.100(a)(3), and to declare the presence of such ingredients in the ingredient statement. Where appropriate, the name of the ingredient may be accompanied by a parenthetical statement such as "(processing aid)" for clarity.

The voluntary declaration of an allergenic ingredient of a color, flavor, or spice could be accomplished by simply naming the allergenic ingredient in the ingredient list. Because such ingredients are normally present at very low levels, the name of the ingredient could generally be placed at the end of the ingredient list and be consistent with its descending order of predominance by weight. Other, non-allergenic ingredients t hat are exempt from declaration would remain unlisted.

Another area of concern is the potential, inadvertent introduction of an allergenic ingredient to a food (e.g., in a bakery that is manufacturing two food products on one production line, one product with peanuts and one without, where traces of peanuts, or peanut products, may end up in the product that does not normally contain peanuts). FDA is considering options for providing consumers with information about the possible presence of allergens in these foods.

The agency is aware that some manufacturers are voluntarily labeling their products with statements such as "may contain (insert name of allergenic ingredient)." FDA advises that, because adhering to good manufacturing practice (GMP) is essential for effective reduction of adverse reactions, such precautionary labeling should not be used in lieu of adherence to GMP. The agency urges manufacturers to take all steps necessary to eliminate cross contamination and to ensure the absence of the identified food. The agency is open to suggestions on how best to address this issue.


Fred R. Shank, Ph.D.

Director, Center for Food Safety and Applied Nutrition

Beverly, I have personally felt comfortable not checking natural flavoring with major US manufacturers; however, with any small manufacturer or one that does not work with FAN, I double check.

You can e-mail FAN to get their advice on this topic to: [email][/email]. I know the natural flavoring aspect was discussed at last year's FAN conference in Chicago. The General Mills rep said they would list any allergen in the product, including Natural Flavoring. Again, that is why I stay with the major manufacturers.


On Feb 27, 1999

Mary, Thank you for taking the time to send me such a thorough reply. You've certainly done your homework. I'm very grateful!

On Mar 18, 1999

are soybeans considered legumes? many products that my son eats contain soybean oil. although he has not had an adverse reaction since eating the cookie with peanut butter he does get occasional rashes on his cheeks sometimes one cheek and sometimes both. could this be from soybean oil? i hope someone has the answer to this because the rashes are making me so nervous. thanks jill

On Mar 18, 1999

Before we knew that my son was allergic to peanuts he was able to eat M&M's with no reaction. That is still true today. Though the allergist said that the trace is not enough to trigger the reaction it could be causing an increase in sensitivity over time. I know of another peanut allergic child that is also able to have M&M's. I wonder if anyone else has been given an opinion on the trace elements over time and reactions. I would say that his reaction to having peanuts is pretty severe so we do try to stay clear of the trace element items just in case. Thanks. Jenny M

On Mar 18, 1999

Hi all. I've been "lurking" for awhile and have greatly appreciated all the information! Jill, my son also gets a rash on his cheeks (and his hands) from soybean oil-he has a class 1 allergy to soybean as well as class 4 to peanuts. The rash pops up where he ususally gets excema breakouts. I do believe that soybeans are legumes. Do legumes need to be avoided when there's a peanut allergy?

[This message has been edited by Dawn (edited March 20, 1999).]

On Mar 20, 1999

Hi Dawn: The legume family includes the following: black-eyed peas, licorice, lima beans, navy beans, PEANUTS, peas, pinto beans, string beans, tragacanth and gum arabic. I copied this list from a book (though unfortunately, and very unusual for me, I neglected to write which book it came from). I've never been told by anyone to avoid all these foods with a peanut allergy, but I don't serve them to my son. Nancy

On Mar 23, 1999

I often see the word "spices" listed in the ingredients, but it doesn't specifiy what the spice is. Does anyone know if peanut could possibly be considered a "spice"?

On Mar 24, 1999

Hi All,

According to literature I received from my son's allergist, it speaks of individual legumes and it states that "in regards to the other members of the legume family, each food stands alone. Just because someone is allergic to peanuts, you do not have to necessarily worry about other legumes. To be sure, each legume must be tested."

We have given our son lima beans with no reaction, but he didn't care for them. This is the only other legume we have tried. I'm still paranoid at trying new foods with him.

Yes...soybeans are a legume.

On Mar 24, 1999

Hi Nancy!

I thought it was acacia gum... What exactly is gum arabic? I never serve my son any of these foods with any of these gums, because I'm not exactly sure what they are. Other gums I'm curious about...xanthan gum and ester gum. Anyone have any idea what these things are?

On Mar 24, 1999

Hi Laura,

I just happen to have a list of the various gums and their descriptions:

AGAR GUM is obtained from a seaweed that grows in Japan. It is used in the food industry as a stabilizer and thickener in ice creams, sauces, cheese products, etc to hold moisture and improve texture in pastry products.

ARABIC GUM - derived from the Acacia species of the legume family and may also be referred to as ACACIA GUM.

GHATTI GUM - comes from a tree that is found in India and Ceylon. It finds use as in an emulsifier in butter, butterscotch and fruit flavorings.

GUAR GUM - obtained from another member of the legume family native to India. It is effective in improving the texture of rice flour recipes.

KARAYA GUM - it is the gum of a tree found in India called Sterculia urens. This gum is used as a thickener in gelatins, gumdrops, fruit ices and ice cream; a flavoring in beverages and as an emulsifier.

LOCUST BEAN GUM - it is obtained from the seed of the carob tree. It is used as a stabilizer and thickener in foods.

TRAGACANTH GUM - is extracted from another species in the legume family. It is used in jellies, ornamental icing, sherbets, fruit ices, salad dressings and candies as a thickener or stabilizer.

XANTHAN GUM - produced by a byproduct of the fermenation of corn sugar by a microorganism called Xanthomonas campestris. It is used as a thickener and stabilizer in salad dressings, sauces, gravies, soups, frozen foods, vegetables, syrups and bakery products.

The above descriptions are brief (if you can believe that) and were given to me at the allergists' office 4 years ago. (This information was taken from a write up from FAN - 1995.

It does go on to state that "allergic reactions to gums are rare. Generally, these ingredients are regarded as safe for most food-allergic individuals."

It might be a good idea to discuss this with your child's allergist for your own piece of mind.

[This message has been edited by Connie (edited March 24, 1999).]

On Mar 24, 1999

Thanks Connie! You sure know your gums!

On May 21, 1999

My allergist alo told me to avoid legumes. Are there any legumes in beer? Is Hops a Legume? What exactly is Lecithin?

On May 22, 1999

Amraff1, do you live near a large or medium sized public library, or a college or university library? If you do, it might be worth while looking at some food encyclopedias or chemical technology or biotechnology encyclopedias. I have found these to be very informative. I am a librarian at a large, urban public library in Canada and I consult these tools when looking for information about ingredients. You might also check to see if there is an allergy or anaphylaxis support group that meets in your area. I get a lot of help and information from the one that I attend.

Take care.

On May 24, 1999

As far as natural flavorings go.. I also called the FDA. I was told that there is a loophole and food mfgs do not have to list them separately, which means they CAN contain peanut flavorings without declaring it. I have called MANY mfgs. They assure me, that "because peanuits is one of the top allergens it would be listed separately". Most of the companies I called "recited" this almost exactly. I also stick to major mfs. with the exception of Quaker. When I called them they advised me not to buy their products because they do not separate the natural flavors. This was the case for Rice a roni and pasta roni product as well.

On Oct 11, 2004

I know this is old ,it has good info!

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